TAX REGULATORY UPDATE · INDONESIA
PMK 55/2026 rewrites the licensing and the supervision of tax consultants and of other parties who act as attorney of a taxpayer
Signed on 22 July 2026, promulgated on 24 August 2026 as Berita Negara Republik Indonesia Tahun 2026 Nomor 589, and in force from the date of promulgation. Prepared on 1 September 2026 from the promulgated text of the regulation itself, so that no implementing rule and no official guidance are covered by it.
What has been replaced
Minister of Finance Regulation Number 55 of 2026 concerning Tax Consultants and Other Parties Acting as Attorneys-in-Fact for Taxpayers revokes Minister of Finance Regulation Number 111/PMK.03/2014, as amended by Minister of Finance Regulation Number 175/PMK.01/2022, pursuant to Article 61, point 2, and takes effect as of the date of its promulgation, pursuant to Article 62.
The authority to carry out the guidance, the development and the supervision of the profession is held by the Minister of Finance, whereas that authority is passed on by mandate or by delegation to the Director General who is responsible for the financial sector and the financial professions, so that the licence, the sanction, the annual report and the certificate of registration of a tax consultant are administered by a unit outside the Directorate General of Taxes, based on Pasal 2 ayat (3), ayat (4) and ayat (5). Joint examination with the unit that formulates tax policy remains open, based on Pasal 34 huruf b.
A second population is brought into the same frame, namely the person who acts as the attorney of a taxpayer while being neither a tax consultant nor a family member, who is now required to hold a Certificate of Registration issued by the Director General, based on Pasal 1 angka 3, Pasal 50 and Pasal 51.
Key highlights
The provisions that carry the most practical weight can be further explained as follows:
- Entry into the profession now runs through the association. An applicant is required to hold a bachelor degree or its equivalent and to have passed the professional examination held by the Tax Consultant Association, together with Indonesian citizenship, competence in taxation, an NPWP, and the absence of any concurrent position in a government body, a state institution or a state-owned enterprise, based on Pasal 5 ayat (2). A person who once served the Ministry of Finance may apply only after five (5) years have passed since retirement or since honourable discharge, based on Pasal 5 ayat (2) huruf l.
- The certificate of competence expires. A Surat Keterangan Kompetensi is valid for three (3) years from the date of issue, may be extended at the earliest one (1) month before it lapses, and is extended only by passing a refresher examination held by the education and training unit of the Ministry of Finance, based on Pasal 10 ayat (7) up to ayat (9). The certificate is also declared void when the licence of the tax consultant is revoked, based on Pasal 42 ayat (2).
- Documented work experience is stated for class B and for class C. Experience of one (1) year accumulated within the last three (3) years is required for class B and experience of two (2) years for class C, evidenced by a letter signed by the head of the firm and by a supervising tax consultant, based on Pasal 5 ayat (3) huruf e. Whereas Pasal 5 ayat (2) huruf e frames the experience as one that follows the class applied for, the list of documents states no period for class A, so that the treatment of a class A application deserves confirmation before it is filed.
- A tax consultant firm may take the form of a limited liability company. The permitted forms are sole practice, persekutuan perdata, firma and perseroan terbatas, subject to a composition test of two thirds (2/3) of the partners or of the directors and commissioners, and subject to a cure period of six (6) months when a partner dies or resigns, based on Pasal 16. A firm opened without the licence of the Minister exposes the founder to suspension of the licence, based on Pasal 15 ayat (3).
- The annual report reaches the level of the individual engagement. The annual report is due on 30 April of the following year and contains the identity of the client, the type of service, the period of the engagement and the fee charged for the service, based on Pasal 28 ayat (2) huruf d and ayat (3), whereas the detail of the services may be submitted on a monthly basis, based on Pasal 28 ayat (4). A firm reports at its own level as well, including its financial statements, based on Pasal 29 ayat (2).
- Sanctions do not have to be imposed in sequence. The Director General may impose a warning, a suspension or a revocation without following the order of severity, based on Pasal 39 ayat (4). Three (3) warnings within the last five (5) years followed by a further breach lead to suspension, and three (3) suspensions on the same count lead to revocation, based on Pasal 40 and Pasal 41. Every suspension and every revocation is announced to the public on the official website, based on Pasal 44 ayat (2).
What this means for a taxpayer
The reporting of the engagement carries the widest practical effect of the whole regulation. The identity of the client, the type of service and the fee charged are placed in the hands of the Ministry of Finance once a year, so that an engagement which the taxpayer treats as confidential is, at the level of its existence and its price, visible to the regulator of the profession. Therefore, the confidentiality clause of an engagement letter deserves to be read again, and the reporting obligation of the consultant deserves to be acknowledged in it rather than contradicted by it.
The class of the licence is the first matter to be checked before a power of attorney is signed. A company with foreign investment, a permanent establishment and a person resident in a treaty partner country are reserved to a class C licence, based on Pasal 4 ayat (4), so that a surat kuasa given to a class B holder by such a taxpayer is defective on scope alone. The same classification governs the Certificate of Registration held by a person who is not a tax consultant, based on Pasal 50 ayat (1).
In-house staff who sign a power of attorney are also affected. A person other than a tax consultant and other than a family member may act as attorney only while holding a Certificate of Registration, which is issued together with the certificate of competence and expires with it after three (3) years, based on Pasal 51 ayat (1) up to ayat (4).
Continuity of the engagement is a risk that can now be checked in advance. A tax consultant under suspension is prohibited from giving the services governed by this regulation, whereas responsibility for the services already given is not released by the suspension, based on Pasal 41 ayat (1) and ayat (2). Since suspensions and revocations are published, the status of an appointed consultant can be verified before an audit or objection deadline makes the substitution costly.
Records survive the relationship, since a tax consultant who resigns declares that the documents connected with the services given will be kept for at least ten (10) years, based on Pasal 48 ayat (3) huruf a, which is the period a taxpayer should also assume for its own defence file.
How the sanctions are graded
| Conduct | Administrative sanction | Basis |
| Services given outside the class of the licence held | Suspension of the licence for three (3) months | Pasal 24 ayat (4) |
| Breach of the Code of Ethics of the association | Suspension for up to two (2) years | Pasal 24 ayat (5) |
| Loss of independence or a conflict of interest | Suspension for up to two (2) years | Pasal 24 ayat (7) |
| Annual report late, not filed, or filed with data that prove untrue | Written warning, and suspension of the licence where the data prove untrue | Pasal 28 ayat (5) and ayat (6) |
| Benefit offered to a tax officer, gratification, extortion, or a concurrent public position | Revocation of the licence, with no re-application permitted | Pasal 30 ayat (4), Pasal 42 ayat (1) |
| Status as a suspect or a defendant in a tax crime | Suspension for the duration of the investigation or the prosecution | Pasal 43 ayat (1) |
The transition, and the one point that needs an answer
The certification run by the panel under the former regulation continues only until 31 December 2026, by which date the professional examination of the association is to be held, based on Pasal 60 huruf e and Pasal 61 angka 1. An Izin Praktik already granted continues as an Izin Konsultan Pajak without a fresh application, based on Pasal 60 huruf a.
The point that needs an answer is Pasal 60 huruf f. A tax consultant certificate issued under the former regulation is treated as a certificate of competence for at most two (2) years counted from the issue of that certificate, whereas most certificates in circulation were issued well before 2024, so that a literal reading leaves their holders with no period left once the association starts its own examination. The question deserves to be raised now rather than in the first quarter of 2027.
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